Order Handling and Best Execution Policy
Goodfolio Limited (“we”, “us”, “Goodfolio”, “the firm”) is a company registered in England and Wales (company number 13402423). Goodfolio is an appointed representative of RiskSave Technologies Ltd (“RiskSave”) which is authorised and regulated by the Financial Conduct Authority (FRN: 775330).
Goodfolio aims to empower environmentally conscious and socially responsible investors by providing transparent, factual investment information directly from the ETF managers enabling them to research ETFs that correlate to their desired ESG theme.
As an appointed representative of RiskSave, Goodfolio also provides investment services to Customers who are classified as Retail Clients for the purposes of the FCA Rules.
The purpose of this Order Handling Policy (the “Policy”) is to describe how the orders you submit to us are handled and how you receive best execution. Providing best execution is a regulatory obligation; it takes into account the nature of a particular order, the prices available, the execution venues available, and a reasonable assessment of relevant execution factors. Goodfolio transmits the orders you submit to a third party, Wealthkernel Limited (“Wealthkernel”) who, in turn, executes those orders.
When you place an order with us, you consent to your orders being executed and/or transmitted in the manner described in this Policy.
The Firm does not execute any orders itself; rather, the Firm will transmit customer orders to Wealthkernel, a UK-based third-party executing broker and custodian, for execution. Under no circumstances will we act in any other capacity. A transaction will arise between the customer and Wealthkernel in all instances for the purposes of the execution of your Order.
The Firm does not receive any benefit (monetary or otherwise) from any trade execution venues (such as Wealthkernel) in return for sending the Firm’s customers’ orders to them.
Our primary obligation is to ensure that your orders are transmitted to Wealthkernel promptly and fairly. Unless instructed otherwise by you or where prevailing market conditions prevent us from doing so, your orders will be transmitted to Wealthkernel sequentially and promptly.
Before you place an order for a security with us, we will provide you with an indicative price of the security. This price is provided by a third party, WealthKernel, and we have no control over them. When your order is executed, it will be executed at the then-prevailing market price, which may differ from the price you are shown when placing an order. We are not liable for any losses suffered as a result of such changes in price.
You acknowledge and agree that indicative pricing information displayed for Securities may change at the time when execution takes place.
If you place an order with us before 12pm (midday), your order will be executed the same day at 3pm . If you place an order with us after 12pm (midday), your order will likely not be executed the same day but be placed for execution the following day at 3pm . At the point of execution, the price of the relevant Instrument may have moved (but we will continue to execute your Order despite those movements).
We will not be liable for any losses you suffer as a result of fluctuations in price whilst submitting an Order.
We receive and transmit orders via our website. These orders are transmitted onwards and then executed as follows:
Execution via Wealthkernel: We will primarily transmit an order to be executed by Wealthkernel unless instructed otherwise or where prevailing market conditions prevent us from doing so.
We shall not act in any other capacity and the transaction which arises shall be between you and the relevant third party broker to execute your order.
Where a Customer provides specific instructions to Goodfolio, Goodfolio will transmit an Order in accordance with those instructions. These specific instructions may prevent Goodfolio from acting in accordance with this Policy, which is designed to ensure Orders are handled and executed in a Customer’s best interests. Where we received specific instructions, those instructions shall be deemed to constitute best execution (to the extent best execution is applicable).
Where those instructions only relate to some aspects of an Order, we will comply with this Policy in relation to the other aspects. A customer’s order may be executed outside of a trading venue. You provide express consent for these orders to be executed outside of a trading venue.
Goodfolio transmits the orders you submit to Wealthkernel. This means that Goodfolio does not execute your orders itself and so does not have to comply with the requirement to achieve best execution.
Transmitting Orders to Wealthkernel
Goodfolio has chosen to primarily transmit orders to Wealthkernel as it has been able to demonstrate that it can consistently achieve the best execution results for Customers. In particular, Goodfolio has confirmed that Wealthkernel has the necessary expertise in relation to the instruments it offers for trading to deliver outcomes at least as good as can be obtained by transmitting orders to other third-party brokers. As part of our terms and conditions, you will have accepted the terms of the Wealthkernel.
Wealthkernel is regulated by the Financial Conduct Authority in the United Kingdom. Wealthkernel is therefore also under an obligation of best execution and is required to publish information on its execution practices and venues which it selects for executing transactions.
Further details of best execution for Wealthkernel may be obtained here, directly from Wealthkernel or supplied by us upon request.
For the avoidance of doubt, Wealthkernel is deemed to have provided best execution where it is receiving and transmitting an Order for execution pursuant to a specific instruction provided by a Customer.
Review of the Third-Party Provider
Goodfolio will review the market landscape in order to determine whether alternative third-party brokers could be selected to replace Wealthkernel.
This assessment takes into consideration, amongst other things, the following metrics:
● frequency of trading;
● resilience; and
● execution price.
These reviews will also occur annually and / or on an ad-hoc basis where a material change occurs that affects Goodfolio’s ability to continue to obtain the best possible result for the execution of orders on a consistent basis using Wealthkernel
Goodfolio will also continue to monitor the quality of execution by Wealthkernel, taking into account the following execution factors to ensure the best possible result:
● size of the order;
● nature of the order;
● likelihood of timely execution and settlement; and
● any other consideration relevant to the efficient execution of the order.
These execution factors may be weighted differently due to market conditions, such as a lack of liquidity being available.
Goodfolio will review and monitor on at least an annual basis the effectiveness of its order handling and best execution arrangements as documented in this Policy in order to:
● identify and implement any required amendments to this Policy;
● ensure the Policy is fit for purpose; and
● ensure the Policy reflects any changes to Applicable Law;
We shall notify you of material changes to this Policy or once we have been notified of any changes to Wealthkernel’s best execution principles which may impact how your orders are transmitted and / or executed.
Goodfolio shall not structure or charge its commissions in such a way as to discriminate unfairly between third party broker(s). Goodfolio shall not receive any third-party payments that do not comply with MiFID II and shall inform Customers about the inducements that the firm may receive from execution venues in accordance with applicable law. In cases where Goodfolio applies different fees depending on the third-party broker selected, Goodfolio will explain these differences to the Customers in sufficient detail to allow the Customers to understand the advantages and disadvantages of the choice of a particular third party broker.
Customers are deemed to consent to this Policy when they agree to Goodfolio’s Terms of Service.
Where applicable, Goodfolio’s duty to provide the Customer with regulatory obligations to best execution does not imply that Goodfolio owes the Customer any fiduciary responsibilities over and above the specific regulatory obligations placed upon it or as may be otherwise contracted between Goodfolio and the Customer. The Customer remains responsible for its investment decisions and Goodfolio will not be responsible for any market trading loss the Customer may suffer as a result of those decisions.
Should you have any further questions about our order handling or best execution, you can contact us:
● by email at email@example.com; or
● by mail at GOODFOLIO, 41 Luke St, London EC2A 4DP